This is the privacy policy of Red Arrow, www.redarrow.ie (‘we’, ‘our’, ‘us’ or ‘Red Arrow’).

Our registered office is at Red Arrow, Tenure, Co. Louth, Ireland

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website and through social media platforms and online retail platforms, including Squarespace and LinkedIn.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

 

Personal data we process

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1.          How we obtain personal data

The information we process about you includes information:

• you have directly provided to us

• that we gather from third party databases and service providers

• as a result of monitoring how you use our website, and what type of products you purchase from us.

2.         Types of personal data we collect directly

When you purchase a product from us, we ask you to provide personal data. This can be categorised into the following groups:

• contact information, such as company name, your name, your email address, your telephone number and your postal addresses for billing, delivery and communication

• records of communication between us including messages sent through our website, email messages and telephone conversations. We do not record or retain audio of telephone conversations.

• marketing preferences that tell us what types of marketing you would like to receive, including reminders to re-order a product

3.         Types of personal data we collect from third parties

We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us.

The additional information we collect can be categorised as follows:

• business information, including your business trading name and address, your company’s registered number (if incorporated), and your VAT number (if registered)

• information that confirms your contact information

4.         Types of personal data we collect from your use of our services

By using our website and our services, we process:

• technical information about the hardware and the software you use to access our website, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system

• usage information, including the frequency you use our services, the pages of our website that you visit

• transaction information that includes the details of the products services you have bought from us and payments made to us for those services

• your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

5.          Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

6.          Special personal data

We do not collect any special personal data about you.

7.          If you do not provide personal data we need

Where we need to collect personal data by law, such as your VAT ID for export sales or VAT 56B authorisation, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

In that case, we may not be able to complete your order. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

8.          Information we process because we have a contractual obligation with you

When you buy a product from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.

We may use it in order to:

• verify your identity for security purposes when you use our services

• sell products to you

• provide you with our services

• provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

9.          Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@redarrow.ie.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

10.      Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means

• whether processing (or not processing) might cause you harm

• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• improving our services

• record-keeping for the proper and necessary administration of our business

• responding to unsolicited communication from you to which we believe you would expect a response

• exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property

• insuring against or obtaining professional advice that is required to manage business risk

• protecting your interests where we believe we have a duty to do so

11.      Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

How and when we process your personal data

12.      Payment information

Payment information is never taken by us or transferred to us through our website. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Stripe. That page may be branded to look like a page on our website, but it is not controlled by us.

13.      Information obtained from third parties

We may sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.

No such information is personally identifiable to you.

14.      Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

15.      Service providers

We may share your personal data with businesses that provide services to us,

As examples:

• we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website

Use of information we collect through automated systems

16.      Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use and interact with our website

• traffic sources, unique visitors

• to record whether you have seen specific messages we display on our website

• to help our shopping cart and check out features work

• cart abandonment

17.      Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

18.      Re-marketing

Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for our services when you visit some other website.

The benefit of re-marketing technology is that we can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.

We may use a third-party advertising service to provide us with re-marketing services from time to time. If you have consented to our use of such tracking technologies, you may see advertisements for our products and services on other websites.

We do not provide your personal data to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of our website.

Other matters

19.      Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at
https://www.dataprotection.ie/en/individuals/rights-individuals-under-general-data-protection-regulation

20.      Use of our products by children

We do not sell products or provide services for purchase by children, nor do we market to children.

21.      Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

22.      Data may be processed outside the European Union

Our website is hosted in Ireland.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within Ireland or any other country could be processed outside the European Union.

We use the following safeguards with respect to data transferred outside the European Union:

• the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority.

23.      Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us, info@redarrow.ie, to request that we provide you with the personal data we hold about you.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

We remind you that we are not obliged by law to delete your personal data or to stop processing it if it prevents us from performing necessary functions. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

24.      Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We do not record or retain audio of telephone conversations.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

25.      Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

You can contact us through our website or use info@redarrow.ie

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Data Protection Commission (DPC). This can be done at https://www.dataprotection.ie/docs/complaints/1592.htm

26.      Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

• to provide you with the products or services you have requested

• to comply with other law, including for the period demanded by our tax authorities

• to support a claim or defence in court

27.      Compliance with the law

Our privacy policy complies with the law in Ireland, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

28.      Review of this privacy policy

We shall update this privacy notice from time to time as necessary.